01Data controller
- Controller
- Vince Nagy-Toma (Axióma Webfejlesztés)
- vince@axiomaweb.eu
- Phone
- +36 20 274 4698
- Website
- https://axiomaweb.eu
I am not required to appoint a data protection officer. You can reach me about any data protection matter using the details above.
02In short
- No cookies, tracking scripts, advertising or social media pixels.
- No external fonts or embedded content: the files of this site are served from this domain. The only exception is the script of Cloudflare’s cookieless visitor statistics.
- I never sell your data or use it for marketing.
- I only process what is needed for communication, performing the contract and meeting legal obligations.
03Visiting the website (technical logs)
When you open the website, your browser sends technical data to the server. This data is processed by the hosting provider (Cloudflare, Inc.) as a processor.
- Data
- IP address, time of the request, requested page, browser and operating system type, referring page.
- Purpose
- Serving the website securely and reliably, preventing attacks (e.g. DDoS), troubleshooting.
- Legal basis
- Legitimate interest — Article 6(1)(f) GDPR.
- Retention
- For a short period in the hosting provider's systems, according to its rules. I do not use this data to identify visitors.
04Visitor statistics
If I measure website traffic, I only use cookieless, aggregated statistics (Cloudflare Web Analytics). It places no cookies on your device, does not follow you across other websites and cannot identify individual visitors. Legal basis: legitimate interest — Article 6(1)(f) GDPR.
05Settings in your browser
If you choose a theme, turn sounds on or off, or dismiss the language suggestion, your choice is remembered in your browser's local storage (localStorage) so that it still applies on your next visit.
This data stays on your device, is never sent to me or any third party and cannot identify you. As it is strictly necessary for a function you explicitly requested, no consent is required (Article 5(3) of the ePrivacy Directive and Section 155 of Hungarian Act C of 2003 on electronic communications). You can delete it at any time in your browser settings.
06Getting in touch
If you contact me by email, phone or social media, I process the data needed to respond.
- Data
- Name, email address, phone number, message content and anything else you provide (e.g. business details, project details).
- Purpose
- Responding to your enquiry, preparing a quote, keeping in touch.
- Legal basis
- Steps taken at your request prior to entering into a contract — Article 6(1)(b) GDPR; for other enquiries, legitimate interest — Article 6(1)(f).
- Retention
- If no contract is concluded, up to 1 year after the enquiry is closed; otherwise as described in the next section.
If you message me on social media (Instagram, Facebook), the platform's own privacy rules (Meta Platforms Ireland Ltd.) also apply.
07Performing the contract and invoicing
- Data
- Name, company name, address, tax number, email address and phone number of the client or contact person, the content and price of the order, related correspondence.
- Purpose
- Performing the contract, communication, invoicing, enforcing possible claims.
- Legal basis
- Performance of a contract — Article 6(1)(b) GDPR; issuing and keeping invoices is a legal obligation — Article 6(1)(c).
- Retention
- Contract data for 5 years after the contract ends (the general limitation period under Hungarian civil law); accounting records for 8 years under Section 169 of Hungarian Act C of 2000 on accounting.
Invoices are issued by the school cooperative I work with, which acts as an independent controller for invoicing data.
08Project access credentials
To start development, the client provides an email address — preferably one created for this purpose — and its password, on which I register the accounts the website needs (e.g. hosting, DNS management, code repository). If the domain was registered earlier, access to the registrar account may also be required.
- Purpose
- Solely to set up, launch and submit the ordered website to Google.
- Legal basis
- Performance of a contract — Article 6(1)(b) GDPR.
- Security
- Credentials are kept confidential, never shared with third parties and used only for the assignment.
- Retention
- Until handover. At handover the client changes the password, which ends my access; I do not keep the previous password.
Please do not give me the password of your personal or main business account — create a new email address for this purpose instead.
09Processors and recipients
- Cloudflare, Inc. (101 Townsend St, San Francisco, CA 94107, USA) — hosting, CDN, DNS, security services and cookieless statistics.
- Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) — email service (Gmail).
- GitHub, Inc. (88 Colin P Kelly Jr St, San Francisco, CA 94107, USA) — storing and publishing website source code.
- The school cooperative issuing invoices — as an independent controller for invoicing data.
Data may only be transferred outside the European Economic Area with appropriate safeguards: the US providers above are certified under the EU–US Data Privacy Framework and/or use the Standard Contractual Clauses adopted by the European Commission.
Data may be disclosed to authorities or courts to the extent required by law.
10Data security
I protect data with appropriate technical and organisational measures: the website is only available over encrypted (HTTPS) connections, accounts are protected with strong passwords and, where possible, two-factor authentication, and access is kept to the necessary minimum. In the event of a personal data breach, I act in accordance with Articles 33–34 GDPR.
11Your rights
- Access — you can ask what data I hold about you (Article 15 GDPR).
- Rectification — you can ask me to correct inaccurate data (Article 16).
- Erasure — you can ask me to delete your data if it is no longer needed or there is no legal basis (Article 17).
- Restriction — you can ask me to restrict processing (Article 18).
- Portability — you can ask for your data in a machine-readable format (Article 20).
- Objection — you can object to processing based on legitimate interest (Article 21).
Send your request to vince@axiomaweb.eu. I respond without undue delay and within one month at the latest; this may be extended by two further months where necessary. Requests are free of charge.
12Remedies
If you have a complaint, please contact me first — I will do my best to resolve it quickly. You also have the right to lodge a complaint with the supervisory authority:
- Authority
- Hungarian National Authority for Data Protection and Freedom of Information (NAIH)
- Address
- 1055 Budapest, Falk Miksa utca 9–11, Hungary; postal: 1363 Budapest, Pf. 9.
- ugyfelszolgalat@naih.hu
- Web
- https://www.naih.hu
You may also complain to the supervisory authority of the EU member state of your habitual residence, place of work or the place of the alleged infringement, and you may take legal action before the competent court.
13Other information
- I do not carry out automated decision-making or profiling.
- Links to reference sites and social networks lead to websites of other providers, whose own privacy rules apply.
- I update this policy when the law or my processing changes. The current version is always available on this page.